2025 Achievements of The Enforcement Resources Committee

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Author: Dina Barabash, Content Development & Web Specialist, Communications
Posted: Sept. 15, 2025

NASBA’s Enforcement Resources Committee (ERC) has been working hard this year. Since its inception, the committee promotes effective, efficient, and, where appropriate, uniform enforcement of professional standards by Boards of Accountancy. Boards of Accountancy are charged with the regulation of the accounting profession for the protection of the public. Many standards have been created to ensure professional services are performed with the greatest level of competency. The committee continues to work with the resources available at NASBA to provide tools to assist the boards with their responsibilities in meeting these standards.

One focus of the ERC this year has been license mobility and how it connects to the Accountancy Licensing Database (ALD). It is often asked how state boards will know if a licensee has been disciplined under mobility practice in another state. The ALD is a valuable resource for mobility discipline. If a mobility state disciplined a licensee practicing under practice privilege in their state, the mobility state’s enforcement information can be submitted to the ALD by the mobility state, even though the individual is not licensed in the mobility state. Mobility discipline information can be sent to the ALD team at NASBA via email ([email protected]). If every board reports its mobility discipline to the ALD, it will greatly help the other jurisdictions with nationwide enforcement efforts and licensure eligibility determinations.

Additional efforts of the ERC this committee year include providing an update to boards on the latest statute and rule amendments. California, Florida, New Hampshire and Washington are examples of state boards with enforcement regulation changes this year. Alaska, Hawaii, Mississippi, Missouri, Nevada, Pennsylvania, Texas and Utah all had enforcement changes to their statutes this year. A comprehensive list of these amendments can be viewed on the NASBA website here.

In July, the ERC invited speaker Mark Brengelman, a distinguished attorney, to lead a well-received webinar called, “Defending a Licensee Before the Board: A View from the Defense Bar.” Brengelman has worked as an assistant attorney general in Kentucky in administrative law, as well as an assigned counsel and prosecuting attorney to numerous health professions’ licensure boards. Currently, he represents two state licensure boards as contract counsel and is a frequent participant in continuing education for many professional associations, including the Federation of Associations of Regulatory Boards, of which NASBA is a long-time member. Brengelman led a lively discussion on how defense attorneys represent licensees before state licensing boards when an enforcement action has gone to a hearing. He provided best practices for boards during administrative panels and hearings when dealing with “the other side” of the bar.

Lastly, in early June, NASBA representatives met with several Federal agencies in Washington, D.C., including the Internal Revenue Service, the Securities & Exchange Commission, the United States Trade Representative, the Public Company Accounting Oversight Board, the Department of Education, and the Department of Health and Human Services.. The goal of the meetings was to encourage collaboration between the federal agencies and NASBA’s member State Boards of Accountancy in enforcement efforts of bad actor CPA licensees. Many Federal agencies impose discipline on CPA licensees and make referrals to the state boards to assess reciprocal discipline. NASBA wants to ensure the communication between the agencies and the state boards is clear and open. In the next edition of the Enforcement Alert, look for more details regarding the D.C. meetings, including best practices for boards handling federal disciplinary referrals and new enforcement resources. The committee continues to work diligently on enforcement resources. The latest information on their efforts can be found in the Enforcement alerts here.