State Boards of Accountancy (State Boards) often deal with enforcement issues arising from services performed by a state board’s licensee before a federal agency. The conduct involved in an enforcement action from the Internal Revenue Service, Securities and Exchange Commission, Public Company Accounting Oversight Board, Department of Education, Health & Human Services, or the Department of Labor may also provide the basis for an enforcement action by the licensing board of the home jurisdiction. Thus, it is important to facilitate the sharing of information between State Boards and these federal agencies, which deal with CPAs and CPA firms. Because the processes for obtaining information can differ among each agency, it is important to discuss each agency’s connection to CPAs and CPA firms along with their disciplinary and referral processes. Each section of this article below gives a brief introduction to the federal agency, an explanation of the agency’s enforcement and referral process (where applicable), and a discussion regarding the process for sharing enforcement information between the agency and state boards. We have also included contact information to assist in the disciplinary referral process. Each section provides important details to assist state board staff in collaboration efforts with federal agencies. At the end of the article, there is a list of NASBA Enforcement Resources that may be helpful to state boards in regards to federal agency discipline.
Securities and Exchange Commission (SEC)
The Securities and Exchange Commission (SEC) has as its mission to protect investors and maintain fair, orderly, and efficient markets and facilitate capital formation. Although many people see the SEC as an agency that regulates the stock market, the SEC has an Enforcement division that pursues securities law violations in federal court and through administrative processes. The SEC conducts its investigations on a confidential basis to maximize their effectiveness and protect the privacy of those involved. Thus, it will generally not be known to the public that an investigation exists unless the SEC brings charges against a person or entity (or a person or entity otherwise discloses the investigation themselves). The SEC has subpoena power to compel witness testimony and require the production of documents such as books and records. The Enforcement division must seek authorization from the Commission prior to bringing cases in federal court or before an administrative law judge. The SEC can charge individuals and entities for violating the federal securities laws and seek remedies such as disgorgement of ill-gotten gains, monetary penalties, injunctions, and restrictions on an individual’s ability to work in the securities industry, serve as an officer or director for a public company, and appear or practice before the Commission as an accountant.
The SEC does not have the power to bring criminal charges. However, the Enforcement division can refer potential criminal cases to criminal authorities involving the same conduct. It is common for many SEC cases to be settled without a trial or litigated administrative proceeding. The SEC’s actions against CPAs are not limited solely to actions involving the practice of accountancy, but may involve insider trading, selling unregistered securities, or embezzlement. CPAs may also be disciplined in connection with accounting misconduct and fraud in regards to services such as financial reporting and can be subject to federal court jurisdiction. Although a felony may not be directly related to the practice of public accountancy, many State Boards have jurisdiction over acts that are discreditable to the profession. Also, the SEC has the authority to bring administrative proceedings to deny an individual the privilege of appearing or practicing before the SEC as an accountant if that individual is found to have engaged in certain types of misconduct.
For more information on SEC Investigations please see their website and review their Enforcement Manual.
How does NASBA work with the SEC?
Like the IRS, the SEC utilizes NASBA’s CPAverify in their enforcement efforts. Additionally, NASBA sends the SEC quarterly highlights which include state legislation of interest and any changes in the accounting profession/licensing requirements along with updated contact information for State Board staff.
How can State Boards work with the SEC?
The SEC, through its Office of the Chief Accountant (“OCA”), notifies relevant State Boards of Accountancy of Commission enforcement actions that involve an accountant who currently is or previously was licensed to practice by a State Board of Accountancy, against whom the Commission has brought an administrative proceeding to deny the accountant the privilege of appearing or practicing before the SEC as an accountant. OCA maintains a state board liaison mailbox for State Boards to communicate with the SEC ([email protected]).
Additionally, though its investigations are confidential and nonpublic, the SEC’s rules permit Enforcement division staff to grant access to nonpublic information in enforcement files to entities that include State Boards of Accountancy pursuant to certain conditions.
For more information on the Access Program, please see the SEC’s Enforcement Manual available online.
SEC Contacts for State Boards:
- Ryan Wolfe, Chief Accountant of Enforcement Division: [email protected]
- Ian Rupell, Division of Enforcement, Attorney-Adviser: [email protected]
- Shehzad Niazi, Acting Chief Counsel, Office of the Chief Accountant: [email protected]
- Patrick Foley, Acting Deputy Chief Counsel, Office of the Chief Accountant: [email protected]
Public Company Accounting Oversight Board (PCAOB)
The Public Company Accounting Oversight Board (PCAOB) is a nonprofit corporation established by Congress to oversee the audits of public companies in order to protect investors and further the public interest in the preparation of informative, accurate, and independent audit reports. The PCAOB also oversees the audits of brokers and dealers registered with the Securities and Exchange Commission (SEC), including compliance reports filed pursuant to federal securities laws. Auditing and accounting are vital to the integrity of our nation’s capital markets, given that investors depend upon accurate, informative and independent audit reports to make informed investment decisions.
The PCAOB sets standards that relate to the profession — including auditing, quality control, ethics, independence and other standards. The PCAOB enforces these professional standards and other related laws and rules governing the audits of public companies and broker-dealers. PCAOB staff investigates potential violations by registered public accounting firms and individual CPAs of these standards, laws, and rules. The PCAOB prioritizes enforcement efforts that address those issues that pose the greatest risk to investors and are most likely to deter improper conduct. PCAOB staff focuses its work on significant audit violations, failures relating to auditor independence, and matters threatening the PCAOB’s oversight integrity (e.g., noncooperation with PCAOB inspections and investigations). When violations are found, the PCAOB may impose sanctions, including censures, monetary penalties, and limitations on a firm’s or an individual’s ability to audit public companies or broker-dealers. The SEC has oversight authority over the PCAOB, including the approval of the Board’s rules, standards, and budget. The PCAOB Division of Enforcement and Investigations coordinates closely with the SEC Division of Enforcement.
Like the IRS and SEC, the PCAOB utilizes NASBA’s CPAverify in their investigative and disciplinary processes.
PCAOB Referrals – How would a State Board receive information for a PCAOB investigation?
How do state boards receive information from the PCAOB when PCAOB investigations and disciplinary proceedings are confidential and nonpublic as required by the Sarbanes-Oxley Act? After a PCAOB action has been taken upon a licensee, State Boards can work directly with Bill Ryan, Chief Counsel, Division of Enforcement and Investigations, and his enforcement team. State boards will request records from the PCAOB by emailing the request to Bill Ryan and his team. Bill’s team will then take the request to the PCAOB Board and seek approval to release the records, with the agreement that the State Board will keep the records confidential.
The PCAOB enforcement staff indicated that they believe the PCAOB has traditionally had good communication with the State Boards, however, not many State Boards reach out to them directly. Like the IRS, the PCAOB would like to hear about more State Board disciplinary updates, if available, as there is an obligation for licensees under PCAOB rules to self-report. The PCAOB would then cross-check their records with State Board enforcement cases. Disciplinary reports can be sent directly to Bill Ryan at [email protected].
The PCAOB reminds State Boards of the Standard Setting and Rulemaking Projects available on their website along with staff writings on PCAOB observations. These are educational resources that are free and easily available to State Boards.
PCAOB contacts for State Boards:
- Bill Ryan, Chief Counsel, Division of Enforcement and Investigations: [email protected]
- John Abell, Chief Accountant, Division of Enforcement and Investigations: [email protected]
- Elliott Mogul, Attorney Assistant Director, Division of Enforcement and Investigations: [email protected]
- Zack Springfield, Accountant Assistant Director, Division of Enforcement and Investigations: [email protected]
The Department of Labor (DOL) oversees many aspects of labor and employment in the United States. The Employee Benefit Security Administration (EBSA) was created under the Employment Retirement Income Security Act of 1974, as amended (ERISA) in order to protect retirement and health benefits created for the benefit of employees and their beneficiaries. Employee benefit plan audits are highly complex and involve a highly regulated environment. Large ERISA-covered benefit plans, generally those covering more than 100 participants, are required to have a financial statement audit performed by an independent CPA in compliance with professional standards. Thus, every plan is audited by a licensee of one of the 55 state boards of accountancy. The Office of the Chief Accountant (OCA), Employee Benefits Security Administration (EBSA), U.S. Department of Labor (DOL), performs assessments of the quality of audit work performed by independent qualified public accountants (IQPAs). OCA staff review audit workpapers of ERISA-covered benefit plan audits each year to identify audit areas that fail to comply with professional audit standards. In cases where OCA’s reviews identify egregious deficiencies, the office refers the CPA firm to the corresponding State Board and currently, where applicable, to the AICPA’s Professional Ethics Division, with the goal that the state board will investigate and take disciplinary action, as appropriate.
The Secretary of Labor is principally responsible for enforcing annual reporting requirements and other fiduciary provisions contained in Title I of ERISA. Specifically, ERISA section 103 requires employee benefit plans to file an annual report of their financial condition and operations with the DOL. This is accomplished through the Form 5500 Annual Return/Report for Employee Benefit Plans. Integral to the Form 5500 is the requirement that almost all plans with over 100 participants include an audit report issued by an IQPA stating whether the plan’s financial statements and other required schedules are presented fairly in conformity with generally accepted accounting principles (GAAP). The audit must be performed in accordance with generally accepted auditing standards (GAAS). While the plan administrator is responsible for selecting and hiring the IQPA, ERISA specifies that they do so on behalf of the plan’s participants and beneficiaries. Almost all plan audits are now performed by CPAs. The DOL plays no role in setting GAAP or GAAS. Such standards are set by institutions closely related to the accounting and auditing industries: the Financial Accounting Standards Board and the AICPA.
A main function of The Office of Chief Accountant (OCA) within EBSA is to provide compliance assistance and enforce the reporting and disclosure provisions of Title I of ERISA. OCA is responsible for establishing and maintaining relationships with private sector professional organizations and regulatory bodies regarding accounting and auditing issues for employee benefit plans. One of OCA’s main goals is to improve the quality of employee benefit plan audits to ensure participants and beneficiaries are receiving the statutory protections that these audits are intended to provide. According to the DOL, an unacceptable number of plan audits continue to fall short of meeting professional auditing standards. This leads to plan participants potentially not receiving the protections provided by a yearly performed audit.
How does the state board obtain information about deficient ERISA audits?
Within EBSA, OCA works with State Boards to enhance the investigation and sanctioning process for CPAs who perform significantly deficient audit work, by coping the AICPA Peer Review program on all referrals the DOL makes to the state boards.
The EBSA has made recent efforts at conferences and on webinars to communicate with State Boards regarding the audit study results. The EBSA has been emphasizing, along with State Boards, the need to ensure that only competent CPAs are performing employee benefit plan audits. The EBSA works closely with state societies of CPAs who have created CPE courses specific to benefit plan audits and is eager to work with other state societies who have not yet made them available to licensees.
If a State Board receives a referral letter from the DOL or otherwise learns of a violation, the State Board can request directly from the licensee that they provide all documentation and correspondence between the licensee and the DOL. Most State Boards have the jurisdiction to discipline a licensee that has violated professional standards in general. Many State Boards have the jurisdiction to discipline a licensee that has been disciplined by a federal agency or national organization through reciprocal discipline statutes.
DOL Contact for State Boards
- Marcus Aron, Acting Chief Accountant, OCA,EBSA: [email protected]; Direct line: 202-693-8371
The U.S. Department of Education (Education) oversees programming such as Kindergarten through grade 12 programs, Federal Student Aid, and other higher education programs. Education disburses about $120 billion in Federal student aid annually and manages or oversees an outstanding loan portfolio valued at more than $1.6 trillion. This makes Education one of the largest financial institutions in the country. As such, effective oversight and monitoring of its programs, operations, and program participants are critical.
The Department also administers more than 100 programs that involve 56 States and territorial educational agencies, more than 17,000 public school districts, about 128,000 schools, and numerous other grantees and subgrantees. Effective oversight of and accountability in how these entities spend the Dept. of Ed. funding they receive is vital.
The Office of Inspector General (OIG) is an independent entity within Education that conducts audits, investigations, and related work to support their mission to identify and stop fraud, waste, abuse, and criminal activity involving Education funds and in turn promote accountability, efficiency, and effectiveness through their oversight of Education’s programs and operations. Through the audit work, the OIG identifies problems and proposes solutions to help ensure that Education programs and operations meet the requirements established by law and that federally funded education services reach the intended recipients—America’s students. Through criminal investigations, the OIG helps protect public education funds for eligible students by identifying those who abuse Education funds and holding them accountable for their unlawful actions.
The Inspector General Act of 1978, as restated (5 U.S.C. §§ 401–424) requires that inspectors general take appropriate steps to ensure that any work performed by non-Federal auditors complies with government auditing standards. To fulfill these requirements, the OIG performs a number of activities, including conducting desk reviews and quality control reviews of non-Federal audits, providing technical assistance, and issuing audit guides to help independent public accountants or audit organizations performing audits of participants in Education’s programs. The Office of Management and Budget’s (OMB) “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards” requires entities—such as State and local governments, universities, and nonprofit organizations—spending $1,000,000 or more in Federal funds during the entity’s fiscal year to obtain an audit, referred to as a “Single Audit.” Additionally, certain for-profit institutions of higher education (schools), foreign schools, and their servicers that participate in Education programs and for-profit lenders and their servicers that participate in Education programs are required to undergo annual audits performed by independent public accountants or audit organizations in accordance with audit guides issued by the OIG. These audits assure the Federal government that recipients of Federal funds comply with laws, regulations, and other requirements that are material to Federal awards.
To help assess the quality of the thousands of audits performed each year, the OIG conducts quality control reviews of a sample of audits. They also perform desk reviews of a sample of audit reporting packages to identify quality issues that may warrant follow-up work, revisions to the reporting package, or appropriate management official attention. The OIG does not publish the results of individual quality control reviews or desk reviews but does publish a summary of it’s oversight activities on a regular basis. A summary of OIG’s 2024 oversight activities, as well as other audit products issued by OIG, is available on OIG’s website at https://oig.ed.gov.
The Council of the Inspectors General on Integrity and Efficiency (CIGIE) issued the following guidance regarding the classification of desk reviews and quality control review results:
- Pass—reporting package or audit documentation contains no quality deficiencies or only minor quality deficiencies that do not require corrective action for the audit under review or future audits.
- Pass with Deficiencies—reporting package or audit documentation contains quality deficiencies that should be brought to the attention of the auditor (and auditee, as appropriate) for correction in future audits.
- Fail—reporting package or audit documentation contains quality deficiencies that affect the reliability of the audit results or audit documentation does not support the opinions contained in the audit report and requires correction for the audit under review.
When the OIG identifies significant quality deficiencies or repeated poor performance by non-Federal auditors, they have traditionally referred them to the American Institute of Certified Public Accountants (AICPA) Professional Ethics Division and their respective State Boards for possible disciplinary action. The OIG typically receives notification from the AICPA regarding disciplinary action taken against an auditor because of a previous referral. The most common actions taken by the AICPA based on OIG referrals include public admonishment and membership suspensions. The OIG would like to receive notifications from the state boards regarding disciplinary action taken against the auditors it refers. There has been some hesitancy in the past to report to the State Board because the OIG did not hear back regarding actions taken and assumed that little to none were carried out by the State Boards. NASBA has worked to correct this narrative and to encourage the OIG to refer the deficient audits directly to the State Boards. NASBA has supported this effort by providing the OIG with the most up to date contact information for State Board staff and counsel on a quarterly basis.
The OIG assures NASBA that it has always referred audit deficiencies to both the State Boards and the AICPA simultaneously. The OIG wants to encourage State Boards to reach out to them for additional work papers if those are needed by the State Board to investigate the case. The OIG would like to see State Boards give more specific CPE to licensees who had a deficient audit as well as more pre-issuance reviews.
Education OIG Contact List for State Boards:
- Mark Priebe, Director, Non-Federal Audit and Financial Statement Oversight Team: [email protected]
- Amy Bales, Assistant Director, Non-Federal Audit and Financial Statement Oversight Team: [email protected]
Department of Health & Human Services
The U.S. Department of Health and Human Services (HHS), Office of Inspector General (OIG) aims to fight waste, fraud, and abuse and to improve the efficiency of more than 100 Department of HHS programs such Medicaid, LIHEAP, and TANF. Under the Single Audit Act Amendments of 1996, a Single Audit is an organization-wide audit of a non-Federal entity’s financial statements and of its expenditures of Federal awards. A Single Audit allows one audit to cover the audit requirements for multiple Federal awards. Single Audits are used as a key monitoring tool to assist HHS-OIG in fulfilling its oversight responsibility to provide assurance that non-Federal entities receiving Federal funds for HHS programs, such as Medicaid, LIHEAP, and TANF are properly administering and using the funds for their intended purposes and in compliance with Federal requirements. Much like the Department of Education, HHS‑OIG uses Single Audit data to make informed management decisions about where to focus its efforts to prevent fraud, waste, and abuse in non-Federal entities’ use of HHS program funds.
HHS is the largest grant-making agency in the Federal Government, and quality Single Audits are a key component of the oversight of Federal funds for HHS programs. Under Title 2 Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), HHS is charged with oversight responsibilities over Single Audits to monitor how recipients are using Federal funds for HHS programs. HHS has implemented the uniform guidance codified in 2 CFR 200 for HHS recipients at 45 CFR Part 75. High-quality Single Audits help HHS-OIG carry out its mission to provide oversight that promotes the economy, efficiency, effectiveness, and integrity of HHS programs.
Like the Department of Education, HHS-OIG assesses the quality and reliability of Single Audits through desk reviews and quality control reviews (QCRs). A desk review is an analysis and evaluation of the data in a Single Audit reporting package that has been submitted to and accepted at the Federal Audit Clearinghouse to ensure compliance with professional auditing standards and Federal reporting requirements. A QCR is a single engagement review that expands the scope of a desk review by performing a more in-depth analysis and evaluation of the underlying audit documentation supporting the planning, fieldwork, and results reported in the Single Audit. HHS-OIG conducts desk reviews and QCRs on Single Audits for which HHS is the designated Federal cognizant or oversight agency. HHS-OIG desk review and QCR oversight activities enable users, including Federal program officials, to confidently rely on the Single Audit data as a monitoring tool to increase the integrity of HHS programs and to hold non-Federal entities accountable for meeting program objectives involving their use of Federal funds. HHS-OIG oversight activities impact program integrity and accountability of Federal funds.
Professional auditing standards and applicable legal regulatory requirements are critical for Single Audits in that they establish a framework for consistent and high-quality audits of entities receiving Federal financial assistance. Single Audits are conducted in accordance with Generally Accepted Auditing Standards (GAAS), Generally Accepted Government Auditing Standards (GAGAS) issued by the Comptroller General of the United States, and the requirements of Title 2 Code of Federal Regulations (CFR) Part 200 (2 CFR Part 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance).
HHS-OIG identifies deficiencies when the information in the report and/or the underlying audit documentation supporting the auditor’s planning, performance, and reporting elements of the Single Audit does not comply with the referenced requirements and standards in a question’s criteria section in the Council of the Inspectors General on Integrity and Efficiency (CIGIE) QCR Guide.
The CIGIE QCR Guide provides three options to rate the quality of the Single Audit based on the QCR:
- Pass,
- Pass with Deficiencies, and
- Fail.
Audit deficiencies are considered fatal flaws in the audit design, execution, or reporting and will result in either:
- a Fail rating, which must be corrected in the audit or reporting package under review, or
- a Pass with Deficiencies rating, which would require correction in future audits.
What does HHS refer to the State Boards?
HHS will refer an audit done by a licensee to the State Board if the audit is determined by HHS to be a “Fail”. HHS aims to collaborate with auditors to bring the audit up to professional standards. If the audit is not quite a fail, but there are technical deficiencies, HHS may refer to the State Boards on a case-by-case basis. HHS will determine whether to make a referral to the State Board by looking at how cooperative the auditor is to make the corrections going forward and the auditor’s knowledge of standards. HHS had their first referral that went directly to a State Board in 2025. Previously, HHS sent their audit deficiency referrals directly to the AICPA only, for various reasons. One reason was due to limitations the AICPA has once a licensee has been disciplined by a State Board in comparison to what options may be available if they take action on the AICPA membership first. Over the past few years, NASBA has worked with HHS to explain to them on the difference between a membership organization and the licensing jurisdiction held by a State Board. NASBA believes this dialogue has encouraged HHS to send audit deficiency referrals directly to State Boards, as well as increased collaboration between HHS, State Boards, and the AICPA in disciplinary matters.
Effective communication between HHS-OIG and stakeholders such as State Boards in the Single Audit community is mutually beneficial so that issues and discrepancies can be addressed to improve audit quality and maintain the integrity of HHS programs. HHS-OIG works to provide clear, accurate, and timely information regarding QCR results.
Department of Health & Human Services Contact List for State Boards:
- Tammie Brown, CPA, Director Single Audit Division, HHS, OIG: [email protected]
Internal Revenue Service (IRS)
The Internal Revenue Service (IRS) is responsible for administering and enforcing the federal tax laws and collecting federal taxes from individuals, businesses, and other entities. Many individual professionals participate in federal tax administration, including CPAs, attorneys, Enrolled Agents (enrolled by the IRS), IRS Annual Filing Season Program (AFSP) participants, and other tax professionals who practice before the IRS, primarily through the representation of taxpayers. A CPA whose tax practice or tax services are limited solely to preparing federal tax returns for compensation is not considered to be practicing as a representative or agent of a taxpayer before the IRS.
The IRS Office of Professional Responsibility (OPR) administers and enforces regulations governing practice before the IRS under Treasury Department Circular No. 230 (Circular 230). Circular 230 establishes the standards of conduct for practitioners who represent taxpayers before the IRS. CPAs who represent taxpayers before the IRS with respect to their rights, privileges or liabilities (not those who act as mere tax return preparers) are subject to Circular 230.
OPR’s authority generally relates to a practitioner’s eligibility to practice before the IRS, rather than to a practitioner’s state professional license. Disciplinary sanctions issued under Circular 230 include censure, suspension, disbarment, and monetary penalty. Because OPR’s authority relates specifically to practice before the IRS, disciplinary sanctions by OPR do not directly affect a practitioner’s CPA license, preparing federal tax returns, or practicing public accountancy under state law. State Boards maintain independent authority over CPA licensure within their home jurisdictions. Accordingly, State Boards may independently determine whether civil penalty assessments or criminal enforcement actions by the IRS or Circular 230 disciplinary sanctions by OPR are relevant to their own licensing or enforcement statutes and regulations.
NASBA met with the IRS at their offices in Washington D.C. in June 2025. NASBA learned that the IRS OPR uses NASBA’s online resources as valuable tools in the office’s casework.
To collaborate on behalf of our State Boards, NASBA sends updates to the IRS regarding legislation and changes in the accountancy profession on a quarterly basis. NASBA also sends the IRS updated contact information for State Board staff on a quarterly basis to ensure any disciplinary referrals sent by the IRS are making it to the correct contact at each State Board. In conjunction with the IRS’ goal of being proactive and timely with their own information and outreach efforts, NASBA’s Enforcement Resources Committee and Legal department continue to arrange IRS webinars and appearances at NASBA conferences.
Information sharing:
The IRS is subject to strict statutory confidentiality rules regarding taxpayer information. In particular, Internal Revenue Code section 6103 generally prohibits the disclosure of federal tax return information except in circumstances specifically authorized by law. Because of these statutory limitations, the information that the IRS and OPR may share externally, including with State Boards, may be limited. Publicly available information, including published disciplinary decisions and other publicly released materials, may provide relevant information for state regulatory authorities. State Boards seeking information about IRS practitioner discipline are encouraged to consult publicly available sources and IRS guidance, including Treasury Department Circular No. 230 and related information available on IRS.gov. Under the U.S. Treasury Department’s published Privacy Act systems of records notices (SORNs) for the records that OPR maintains, certain routine uses of the records provide for disclosure of non-tax information to state licensing and comparable authorities; the scope of releasability goes beyond the Privacy Act information that is shareable with the general public on irs.gov (in the Announcements included in the Internal Revenue Bulletin (IRB), Disciplinary Look-up, etc.) (see Office of Professional Responsibility and Circular 230). For case specific information requests, it is recommended to contact the OPR for more information and assistance.
How the State Boards and the IRS can work together:
The IRS currently receives some publicly available enforcement matters directly from State Boards; however, OPR representatives told NASBA in June that their office would like to expand the number of referrals. The IRS is interested in hearing about more State Board announcements (or equivalent statements) of discipline. The best way to inform the IRS of state disciplinary action is to copy them on publications and direct communication to [email protected]. The IRS currently receives disciplinary information from all 50 of the state bars for attorney licensees and would like to see an increase in information from State Boards. However, NASBA informed the IRS that State Boards may have their own restrictions on sharing enforcement information to federal agencies. If an exception for this type of information sharing applies to your State Board, please feel free to include the IRS on future disciplinary notices.
As a reminder, the IRS OPR only has jurisdiction over the CPAs who practice before the IRS.
IRS OPR Contacts for State Boards:
- Tom Curtin, Acting Director: [email protected]
- Keith Ott, Attorney Advisor: [email protected]
- Diana O’Neill, Management & Program Analyst: diana.m.o’[email protected]
NASBA Enforcement Resources
The Enforcement Resources Committee works with NASBA staff to provide resources and tools on the NASBA website to assist Boards with protecting the public through investigation and enforcement efforts. Below outlines a few of the enforcement tools available to NASBA member boards.
The Enforcement Resources Committee continues to work with NASBA to gather information from federal agencies regarding disciplinary or enforcement matters involving CPAs or CPA firms that might be of interest to Boards. The Quarterly Enforcement Report is currently a compilation of information obtained from publicly available information on the websites of the following federal agencies and national organizations: Securities & Exchange Commission, Internal Revenue Service, PCAOB and AICPA.
The Enforcement Newsletter provides important information on recent topics, legislation, and rulemaking pertaining to disciplinary matters and measures at state boards.
The Enforcement Resource Guide addresses the various stages of the enforcement process, from start to finish, and is divided into nine components. The Guide also includes sample forms and board models.
NASBA’s Board Counsel Boot Camp resource is designed to provide pertinent information regarding the regulation of the accountancy profession for legal counsel newly appointed to state boards of accountancy. This information may also be useful for new board executive directors, investigators, and enforcement staff to familiarize themselves with nuances of the accountancy profession as it pertains to their specific role. These materials will provide an overview of the accountancy profession, cover different regulatory oversight pathways for CPAs, explain advocacy groups, as well as provide key concepts of the CPA profession including Mobility and Peer Review.
The Investigator Training Series includes six modules created to provide introductory training for investigators assigned to investigate a complaint for a Board of Accountancy. Please click the titles of each module to open them in a new window/tab. Some of our Boards have requested that we provide quizzes and certificates of completion for the training modules. The presentations can be viewed without participating in the quizzes.